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Process Safety Management of Highly Hazardous Chemicals. Nancy J Bethea. Process Safety Management (PSM). Is the proactive identification, evaluation and mitigation or prevention of chemical releases that could occur as a result of failures in processes, procedures, or equipment. Purpose.

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Process Safety Managementof HighlyHazardous Chemicals

Nancy J Bethea


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Process Safety Management (PSM)

Is the proactive identification, evaluation and mitigation or prevention of chemical releases that could occur as a result of failures in processes, procedures, or equipment.


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Purpose

  • Prevent Catastrophic Releases of Highly Hazardous Chemicals

  • Minimize Consequences of Such Releases to Employees and the Community


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Catastrophic Events

Deaths Injuries

  • 1984 Mexico City 650 --

  • 1984 Bhopal, India 2500 --

  • 1984 Chicago area 17 17

  • 1985 West Virginia -- 135

  • 1988 New Orleans 5 23

  • 1988 Henderson, NV 2 350


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Catastrophic Events

Deaths Injuries

  • 1989 Pasadena, TX 23 130

  • 1990 Houston, TX 17 --

  • 1990 Cincinnati, OH 2 72

  • 1991 Lake Charles, LA 5 --

  • 1991 Sterlington, LA 8 120

  • 1991 Charleston, SC 6 33

  • 1991 Seadrift, TX 1 32


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Process Safety Management

Bhopal (’84): focused OSHA’s attention

Institute, WV(’85): shows disasters can happen here

1988-1991: concern of public & Congress increases with each event

Feb. 24, 1992: standard in Federal Register


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29 CFR 1910.119

OSHA’s Process Safety

Management Standard


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Anticipated Benefits

OSHA estimated that the integrated

approach of the PSM standard would reduce

the average annual number of deaths (265)

by 200 and reduce the average annual

number of serious injuries (900) by 700 in

industries involved with highly hazardous

chemicals.


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Resources

  • European Economic Community (EEC)

  • World Bank

  • International Labor Office (ILO)

  • U.S. Environmental Protection Agency

  • Superfund Amendments and Reauthorization Act (SARA)

  • States, Industry, & Labor Organizations


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PSM Standard

Performance

NOT

Specification Standard


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PSM Standard

  • Process Safety Information

  • Process Hazard Analysis

  • Operating Procedures

  • Training

  • Contractors

  • Pre-startup Safety Review


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PSM Standard

  • Mechanical Integrity

  • Hot-work Permits

  • Management of Change

  • Incident Investigations

  • Emergency Planning & Response

  • Compliance Safety Audits


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What’s Covered

  • Listed Chemicals in Appendix A

  • > 10,000 pounds of Flammable Liquids or Gases


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Examples of Covered Chemicals

Acetaldehyde Chlorine

Nitromethane Ethylamine

Perchloric Acid Phosgene

Tetramethyl Lead Ketone

HF NO


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What’s Not Covered

  • HC fuels used only for workplace consumption and if not a part of a covered hazardous process

  • Flammable liquids stored or transferred below NBP w/o chilling or refrigeration

  • Retail facilities

  • Oil, gas well drilling, servicing

  • Normally unmanned remote facilities


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Process Safety Information:Chemicals

  • Toxicity

  • PEL

  • Physical Data

  • Reactivity and Corrosivity

  • Thermal and Chemical Stability

  • Effects of Mixing Chemicals


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Process Safety Information:Process

  • Block flow or process flow diagram

  • Process chemistry

  • Maximum intended inventory


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Process Safety Information:Process

  • Safe upper/lower limits for such items as temperatures, pressures, flows or compositions

  • Consequences of deviations, e.g. runaway reaction potential


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Process Safety Information:Equipment

  • Materials of construction

  • P&IDs

  • Electrical Classification

  • Relief system design & design basis


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Process Safety Information:Equipment

  • Ventilation system design

  • Design codes and standards

  • Material & energy balances

  • Safety systems


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Process Hazard Analysis

Organized and systematic effort to identify and analyze the significance of potential hazards associated with the processing or handling of highly hazardous chemicals


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Process Hazard Analysis

  • Causes/consequences of fires & explosions

  • Releases of toxic or flammable chemicals

  • Major spills of hazardous chemicals

  • Methodology depends on the process & its characteristics


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PHA Focuses On

  • Equipment

  • Instrumentation

  • Utilities

  • Human Actions

  • External Factors


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Process Hazard Analysis

  • What If?

  • Checklist

  • What If?/Checklist

  • Hazard & Operability Study (HAZOP)

  • Failure Mode & Effects Analysis (FMEA)

  • Fault Tree Analysis (FTA)


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PHA Must Address

  • Hazards of the process

  • Engineering & administrative controls

  • Consequences of failure of controls

  • Facility siting


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PHA Must Address

  • Human factors

  • Evaluate potential effects to on-site personnel from failure of controls

  • Identification of previous incidents


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PHA Team

  • Expertise in engineering & process operations

  • One member to have knowledge of & experience with process being evaluated


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PHA Team

  • One member knowledgeable in specific PHA methodology used for evaluating the process

  • Other members with specific knowledge: instrumentation, chemistry, etc.


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Employer PHA Actions

  • Establish system for prompt response

  • Ensure timely resolution of findings & recommendations

  • Document actions taken


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Employer PHA Actions

  • Develop written schedule for completions

  • Complete actions ASAP

  • Communicate actions to affected employees


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Operating Procedures

  • Provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information

  • Address at least the listed elements


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Operating Procedures:Steps for Each Operating Phase

  • Initial startup, operation, shutdown

  • Temporary & emergency operations, emergency shutdown

  • Startup following shutdowns


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Operating Procedures: Operating limits

  • consequences of deviations

  • prevention of deviations


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Operating Procedures: Safety & Health Considerations

  • Chemical properties and hazards

  • Precautions to prevent exposure

  • Control measures if contact or airborne exposure occurs


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Operating Procedures: Safety & Health Considerations

  • Quality controls for raw materials

  • Control of hazardous chemical inventories

  • Special or unique hazards

  • Safety systems & their functions


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Operating Procedures

  • Operating procedures readily accessible

  • Reviewed as necessary to reflect current procedures and changes

  • Certified annually as current & accurate


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Operating Procedures

  • Develop & implement safe work practices to provide for the control of hazards during operations, e.g. lockout/tagout/ confined space entry, opening equipment & pipes, facility entry

  • Apply to employees & contractor employees


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Training

  • Process overview

  • Process hazards

  • Operating procedures

  • Emergency procedures

  • Refresher training at least every 3 yrs

  • Documentation


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Employer Responsibilities

  • Evaluate contractor’s safety performance & programs

  • Inform contractor of potential hazards: fire, explosion, toxic release, applicable plant safety rules

  • Develop/Implement safe work practices

  • Evaluate contractor performance


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Contractor Responsibilities

  • Advise employer of any unique work hazards of contracted work

  • Each employee follow all applicable work practices & safety rules of the facility

  • Ensure each employee is trained in necessary work practices


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Contractor Responsibilities

  • Ensure each employee is instructed in known fire, explosion, or toxic release problems related to his/her job

  • Document that understanding of training has been evaluated, verified


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Pre-startup Safety Review

Done when:

  • New processes

  • Modified process


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Pre-startup Review Verifies

  • Construction: conforms to design

  • Procedures: adequate, in place

  • PHA recommendations resolved or implemented

  • Management of change requirements met

  • All affected workers trained


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PSM Mechanical Integrity

  • Pressure vessels, storage tanks

  • Piping systems, components

  • Relief & vent systems, devices

  • Emergency shutdown systems

  • Controls: monitoring devices, sensors, alarms, interlocks

  • Pumps


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Mechanical Integrity

  • Written procedures

  • Training: process hazards, job tasks

  • Inspections

  • Testing

  • Corrective action

  • Records


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Hot Work Permits

  • Welding, cutting, brazing

  • Control of ignition sources

  • Verify safe conditions

  • Authorization


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Management of Change

  • Establish written procedures

  • Develop management support

  • Evaluate safety of any changes to:

    process chemicals facility

    technology equipment


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MOC Procedures Must Address

  • Everything except “replacement in kind”

  • Temporary as well as permanent changes

  • Technical basis for change

  • Safety & health effects


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MOC Procedures Must Address

  • Modified operation procedures

  • Time necessary for change

  • Authorization for change

  • Ways to inform & train workers before change


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Incident Investigation Goals

Identify incident causes and implement steps to prevent reoccurence


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Incident Investigation

  • Every incident

  • Prompt investigation

  • Knowledgeable team

  • Documentation & report

  • Recommendations & findings

  • Resolutions & corrective actions


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Emergency Planning & Response

  • Develop Emergency Action Plans

  • Pre-plan for catastrophe

  • Train & equip workers

  • Drills


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Compliance Safety Audits

  • Certify all elements of standard

  • Knowledgeable audit team

  • Report & recommendations

  • Address all finding & recommendations

  • Conduct every three years


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Appendices

A: List of chemicals

B: Sample block & flow diagrams

C: Compliance guidelines

D: References


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